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vs. Epstein, et at. 
Case No.: 08-CV-80811-CIV-MARRNJOHNSON 
Plaintiffs Motion for Protective Order 
condition "in controversy" such that it operates as a waiver of the psychotherapist-
patient privilege. 
WHEREFORE, Plaintiff, MI, , respectfully requests that this Court enter a 
protective order preventing the discovery of Plaintiffs treatment records from the 
Parent-Child Center, Inc. and Dr. Serge Thys until such time as the Court decides 
whether the statutory damages pursuant to 18 U.S.C. §2255 are available to a victim of 
an enumerated sexual offense on a per incident basis. 
CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1 
Counsel for the movant conferred via telephone with counsel for the Defendant 
and counsel for the Defendant is not in agreement with Plaintiff's Motion For Protective 
Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge 
Thys and Incorporated Memorandum of Law. 
s/ Jack P. Hill 
5 
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. vs. Epstein, et al. 
ase No.: 08-CV-80811-CIV-MARRNJOHNSON 
Plaintiffs Motion for Protective Order 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on the 5th day of June, 2009, I electronically filed the 
foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice 
of electronic filing to all counsel of record on the attached service list. 
istlank P Hill 
Jack Scarola 
Florida Bar No.: 
Jack P. Hill 
Florida Bar No.: 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm 6409 
Phone: 
Fax: 
Attorneys for Plaintiff 
6 
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Mit. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRAIJOHNSON 
Plaintiffs Motion for Protective Order 
COUNSEL LIST 
Richard H. Willits, Esquire 
Richard H. Willits, P.A. 
2290 10th Avenue North, Suite 404 
Lake Worth, 
Phone: 
Fax: 
Robert Critton, Esquire 
Burman Critton Luther & Coleman LLP 
515 North Flagler Drive, Suite 400 
West Palm B 
4 
Phone: 
Fax: 
Jack A. Goldberger, Esquire 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South 
West Palm Brat Fl 3340 
Phone: 
Bruce E. Reinhart, Esquire 
Bruce E. Reinhart, P.A. 
250 South Australian Avenue 
Suite 1400 
West Palm B 
Phone: 
Fax: 
7 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON 
VS. 
Plaintiff, 
JEFFREY EPSTEIN and 
Defendants. 
ORDER ON PLAINTIFF, C.M.A'S MOTION FOR PROTECTIVE ORDER REGARDING 
TREATMENT RECORDS FROM PARENT-CHILD CENTER, INC. AND DR. SERGE 
THYS AND INCORPORATED MEMORANDUM OF LAW 
This matter came before the Court upon the Plaintiff's Motion For Protective 
Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge 
Thys and Incorporated Memorandum of Law. Having considered the motion, it is 
hereby ORDERED and ADJUDGED that: 
Plaintiffs Motion for Protective Order is hereby GRANTED. 
DONE AND ORDERED this 
day of June, 2009. 
KENNETH A. MARRA 
United States District Judge 
Copies to all Counsel of Record 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
JANE DOE NO. 2, 
CASE NO.: 08-CV-801 I 9-MARRA/JOHNSON 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
JANE DOE NO. 3, 
CASE NO.: 08-CV-80232-MARRA/JOHNSON 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
JANE DOE NO. 4, 
CASE NO.: 08-CV-80380-MARRA/JOHNSON 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
JANE DOE NO. 5, 
CASE NO.: 08-CV-80381-MARRA/JOHNSON 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
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JANE DOE NO. 6, 
CASE NO.: 08-CV-80994-MARRA/JOHNSON 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
JANE DOE NO. 7, 
CASE NO.: 08- CV-80993-MARRA/JOHNSON 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
CASE NO.: 08- CV-8081 I -MARRA/JOHNSON 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
JANE DOE, 
CASE NO.: 08- CV-80893-MARRA/JOHNSON 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, et al., 
Defendant. 
DOE II, 
CASE NO.: 08-CV- 80469-MARRA/JOHNSON 
VS. 
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JEFFREY EPSTEIN et al., 
Defendant. 
JANE DOE NO. 101, 
CASE NO.: 08- CV-8059 I -MARRA/JOIINSON 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
JANE DOE NO. 102, 
CASE NO.: 08- CV-80656-MARRA/JOHNSON 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
PLAINTIFFS JANE DOES 2-7'S RESPONSE TO DEFENDANT'S MOTION TO 
COMPEL AND/OR IDENTIFY PLAINTIFFS IN THE STYLE OF THIS CASE AND 
MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY SUBPOENAS FOR 
PURPOSES OF DISCOVERY, OR ALTERNATIVELY, MOTION TO DISMISS 
"SUA SPONTE", WITH INCORPORATED MEMORANDUM OF LAW 
Plaintiffs, JANE DOES 2-7, hereby serve their Response to Defendant's Motion to 
Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane Doe in 
Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss "Sua 
Sponte", With Incorporated Memorandum of Law, and state as follows: 
I. 
The lawsuits filed by JANE DOES 2-7 involve private, intimate facts pertaining 
to their own childhood sexual abuse and exploitation by Defendant Jeffrey Epstein. 
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2. 
Jane Does 2-7 filed their suits under a pseudonym' to prevent public disclosure of 
the private, highly sensitive and intimate facts pertaining to their sexual assaults, and the public 
association of their identities with Defendant Epstein and these assaults. 
3. 
Dr. Gilbert Kliman,2 a well-known forensic psychiatrist with an expertise in the 
field of child trauma, has met with and evaluated each of Jane Does 2-7 and opined that public 
disclosure of their real names would create a substantial risk to them of further psychological 
harm. See Exhibit "A", Declaration of Gilbert Kliman, M.D. 
4. 
Dr. Kliman opines as follows: 
Releasing names of the plaintiffs to the public will reenact experiences of 
powerlessness and helplessness in the face of a boundary violation. Repetition and 
reenactment represent central features of Criterion I3 in the DSM-IV-TR diagnosis 
of posttraumatic stress disorder trauma. In effect, release of their identity and 
public intrusion into their personal life represents a reenactment of the shame of 
sexual traumatization. Repetition and reenactment arc central pathologies that 
afflict sexual trauma survivors. 
Victims of sexual abuse often rely upon some form of dissociation, splitting or 
denial, as a defensive means to manage overwhelming affects associated with the 
sexual trauma. Each of the plaintiff girls has employed some variation of this 
defense, both during the massages and then subsequently following disclosure of 
the abuse. Primitive, maladaptive responses of this nature will become 
additionally reinforced as a result of public disclosure. 
Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, 
is that the trauma was associated with human design factors (such as cruel 
intention to do harm, rape, torture). Trauma of this origin has a tendency to 
produce more "severe or long lasting" posttraumatic stress disorder than natural 
events (DSM IV TR p. 464). A policy of deliberate revelation of the names of the 
victims would reinforce the sense of design, pattern and policy of human 
intentions. 
It is my opinion, with a reasonably high degree of medical certainty that the 
defense motion to allow public disclosure of the plaintiffs' identity is clinically 
Defendant and his counsel are aware of the real names of Jane Does 2-7. 
2 A copy of the curriculum vitae of Dr. Gilbert Kliman is attached hereto as Exhibit "B". 
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and ethically a wrongful plan. The act of revealing their identity against their 
wishes places the plaintiffs at risk, in the best of circumstances, of suffering an 
aggravation of existing diagnostic concerns. It is more probable than not that 
releasing personal identities will foster an exacerbation and magnification of 
symptoms lending to increased risk of revictimization and retraumatization. 
See Exhibit "A", ¶¶ 13-15, 21 
5. 
Given the private nature of the allegations in this lawsuit and the serious risk of 
harm to the mental health of Jane Does 2-7 if a public disclosure of their identities were required, 
Jane Does 2-7 should be permitted to continue using a pseudonym in this lawsuit. 
6. 
Notably, in one of the cases consolidated for purposes of discovery, Jane Doe v. 
Jeffrey Epstein, Case No. 08-80893, this Court recognized the harm likely to result from public 
disclosure of the victims' identities in these cases, and allowed the Plaintiff in that case to 
"proceed in this action under the pseudonym 'Jane Doe' ", by Order dated October 6, 2008. 
7. 
Jeffrey Epstein sets forth no facts to support his bare contention that Jane Does 2-
7 use of a pseudonym in these proceedings interferes with his "constitutional due process right." 
See Motion to Compel, p. 3. Defendant and his counsel know the identities of these Plaintiffs. 
8. 
Defendant also requests the Court's permission to use the real names of Jane Does 
2-7 in various third-party subpoenas for discovery purposes. Defendant does not identify any of 
the entities or persons to whom he intends to send subpoenas. An order granting the relief 
requested without limitations would essentially nullify Jane Does 2-7's right to proceed 
anonymously. Jane Does 2-7 therefore object to the issuance of third-party subpoenas, and 
submit that Defendant can obtain the discovery he seeks by alternative means that will preserve 
the confidentiality of the Jane Does 2-7's identities. 
9. 
If this Court were to permit third party subpoenas or records custodian 
depositions using the existing captions and identifying Jane Does 2-7 in the body of the 
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subpoena by their names, due to publicity surrounding the Defendant's crimes, then Jane Does 2-
7 would effectively be revealed as abuse victims in these cases against Defendant Epstein. Any 
subpoenas or notices to third parties therefore should not disclose the type of action or the 
Defendant's identity. There are alternatives which would preserve Jane Does 2-7's anonymity 
and be more efficient and cost-effective at the same time. For instance, Defendant can obtain 
records from various non-party sources through Plaintiffs' counsel, who can certify that they 
have obtained the records through authorizations signed by Jane Does 2-7. Another means to 
obtain non-party records concerning Plaintiffs is the appointment of a special master, who would 
verify authenticity and completeness of the records. 
10. 
Finally, Jeffrey Epstein's request that this Court order a "sua sponte" dismissal is 
illogical. Sua sponte means "[w]ithout prompting or suggestion; on its own motion." Black's 
Law Dictionary 1437 (7th ed.1999). Thus, the definition of sua sponte does not fit these 
circumstances, because the Court is being prompted by Epstein's Motion. Velchez v. Carnival 
Corp:, 331 F.3d 1207 (11th Cir. 2003). In any event, there is no basis or authority to support a 
dismissal of these cases. 
WHEREFORE, Plaintiffs Jane Does 2-7 respectfully request that (i) this Court deny 
Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to 
Identify Jane Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion 
to Dismiss "Sua Sponte", in its entirety; (ii) Plaintiffs Jane Does 2-7 be permitted to continue 
using their pseudonyms in this litigation; (iii) this Court order that records from non-parties 
relating to Jane Does 2-7, including medical and employment records, only be obtained through 
Plaintiffs' counsel by means of signed authorizations that do not include the caption or identify 
Epstein as the party seeking records, or alternatively, appoint a special master to obtain the 
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records, who would verify authenticity and completeness of the records; and (iv) all other relief 
this Court deems just and appropriate. 
MEMORANDUM OF LAW 
I. 
PLAINTIFFS JANE DOES 2-7 SHOULD BE PERMITTED 
TO PROCEED ANONYMOUSLY IN THIS CASE DUE TO THE 
SENSITIVE, PRIVATE NATURE OF THE UNDERLYING FACTS 
AND THE RISK OF PSYCHOLOGICAL HARM TO THE PLAINTIFFS 
Federal courts permit a party to proceed under a pseudonym when special circumstances 
warrant anonymity. See, e.g., Roe v. Aware Woman Cm for Choice, Inc., 253 F.3d 678, 685-87 
(11th Cir.2001); Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1068-69 (9th 
Cir.2000); James v. Jacobson, 6 F.3d 233, 238-39 (4th Cir.I 993); Ill v. New York Blood Center, 
213 F.R.D. 108, 110-12 (E.D.N.Y.2003); Javier v. Garcia-Botello, 211 F.R.D. 194, 196 
(W.D.N.Y.2002); Doe v. Smith, 105 F.Supp.2d 40, 43-44 (E.D.N.Y.1999); Doe v. United Servs. 
Life Ins. Co., 123 F.R.D. 437, 439 (S.D.N.Y.1988). Sexual assault victims are a paradigmatic 
example of those entitled to a grant of anonymity. See Doe No. 2 v. Kolko, 242 F.R.D. 193 (ED. 
N.Y. 2006); Doe v. Blue Cross & Blue Shield United of Wisc., 112 F.3d 869, 872 (7th Cir.1997) 
("fictitious names are allowed when necessary to protect the privacy of... rape victims, and other 
particularly vulnerable parties or witnesses"); see also Doe v. City of Chicago, 360 F.3d 667, 669 
(7th Cir. 2004). 
The decision whether to allow a plaintiff to proceed anonymously is within the court's 
discretion. See Aware Woman Cir., 253 F.3d at 684; Javier, 211 F.R.D. at 195; t 
213 F.R.D. 
at 110. As set forth above, this Court exercised its direction in one of the consolidated cases, 
Jane Doe v. Jeffrey Epstein, Case No. 08-80893, to allow a plaintiff to proceed under the 
pseudonym "Jane Doe" in an Order dated October 6, 2008. 
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Courts will permit a party to proceed under a pseudonym where "the party's need for 
anonymity outweighs prejudice to the opposing party and the public's interest in knowing the 
party's identity." Does I Thru /VC II, 214 F.3d at 1068; see Javier, 211 F.R.D. at 195; EW, 213 
F.R.D. at III; As set forth herein, the balancing test in this case weighs in favor of permitted 
plaintiff to continue to proceed anonymously: 
In undertaking this balance, courts have considered such facts as 
(I) whether the plaintiff is suing the government or a private 
person; (2) whether the plaintiff would be compelled to disclose 
intimate information; (3) whether plaintiff would be compelled to 
his or her intention in engage in illegal conduct, thereby risking 
criminal prosecution; (4) whether the plaintiff would risk injury if 
identified; (5) whether the party defending against a suit brought 
under a pseudonym would thereby be prejudiced; (6) the ages of 
the parties whose identity is to be suppressed; (7) the extent to 
which the identity of the litigant has been kept confidential; (8) 
whether, because of the purely legal nature of the issues presented 
or otherwise, there is an atypically weak public interest in knowing 
the litigants' identities; and (9) the public interest in guaranteeing 
open access to proceedings without denying litigants access to the 
justice system. 
Doe v. Del Rio 241 F.R.D. 154, 157 (S.D. N.Y. 2006) 
The public has a strong interest in protecting the identities of sexual assault victims so 
that other victims will not be deterred from reporting such crimes. See Doe v. Evans, 202 F.R.D. 
173, 176 (E.D.Pa.2001) (granting anonymity to sexual assault victim); Doe No. 2 v. Kolko, 242 
F.R.D. 193 (E.D. N.Y. 2006). That is particularly true in these consolidated cases where there 
are numerous victims with similar claims. Although these cases have gained considerable media 
attention, there appears to be little public interest in knowing the specific identity of each of the 
victims. 
With regard to the second factor, courts have granted anonymity to protect against 
disclosure of a wide range of issues involving matters of the utmost intimacy, including sexual 
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assault. See, e.g., Aware Woman Cir., 253 F.3d at 685 (abortion); ■ 
213 F.R.D. at III 
(infection with hepatitis B); Doe v. Evans, 202 F.R.D. 173, 176 (E.D.Pa.200 I) (sexual assault 
victim); Smith, 105 F.Supp.2d at 42 (sexual assault victim); WGA v. Priority Pharmacy, Inc., 184 
F.R.D. 616, 617 (E.D.Mo.1999) (status as AIDS patient); Doe v. United Servs. Life Ins. Co., 123 
F.R.D. 437, 439 (S.D.N.Y.1988) (sexual orientation); see also Blue Cross, 112 F.3d at 872 
(recognizing rape victims as entitled to anonymity). It cannot be reasonably denied that a 
person's sexual history — especially during their childhood — is an intimate fact. When the 
childhood sexual history includes criminal sexual contact by an adult, the facts are even more 
intimate and personal. In the electronic age in which we live, these concerns are heightened. As 
federal courts have recognized in this context, it is now possible to "determine whether a given 
individual is a party to a lawsuit in federal court anywhere in the country by the simplest of 
computer searches, to access the docket sheet of any such case electronically, and ... that entire 
case files will be accessible over the Internet." Doe v. City of New York, 201 F.R.D. 100, 102 
(S.D.N.Y.2001) (denying anonymity where any injury was purely reputational and case did not 
involve private or intimate matter); see 
213 F.R.D. at 112-13. 
As Dr. Kliman explains in his Declaration, disclosure of Jane Does 2-7's identities will 
place these Plaintiffs "at-risk of having their personal lives scrutinized by friends, extended 
family, spouses, children, fellow students, employers and fellow employees, the media and 
general public. This type of exposure humiliates many victims and represents another betrayal of 
trust. Public exposure places the plaintiff's at further risk of stigmatization, shame and 
retraumatization." See Exhibit "A" at ¶ 3. Dr. Kliman also finds it of no consequence that some 
of the plaintiffs are now legally adults in that "[d]ue to traumatization the plaintiffs are arrested 
in their development, and even those who are now legally adult are arrested in part to adolescent 
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aspects of psychology." Id. at ¶ 4 
The policy of protecting victims of sexual misconduct from undue embarrassment and 
disclosure of their private affairs is firmly established in Fed.R.Evid. 412. The protections of 
Rule 412 are designed to "encourage victims of sexual misconduct to institute and participate in 
legal proceedings against alleged offenders." (Committee Notes to 1994 Amendment). 
Likewise, many states in this country, including Florida and New York, have similarly enacted 
laws to protect the anonymity of sexual assault victims. See Fla. Stat. §§794.024, 794.026 
(2008); N.Y. Civil Rights Law § 50-b (McKinney 2009). In 1994, the Florida Legislature passed 
The Crime Victims Protections Act. The legislative stated purpose for the Act was "to protect 
the identity of victims of sexual crimes." Fla. AGO, 2003-56, 2003 WL 22971082 (Dec. 15, 
2003). Under §794.024, Florida Statutes, court records that identify the name and/or address of a 
victim of a sexual crime are presumed to be confidential and exempt from public access. Id. 
Similarly, upon approving New York's rape shield law, then Governor Mario Cuomo stated, 
"sexual assault victims have unfortunately had to endure a terrible invasion of their physical 
privacy. They have a right to expect that this violation will not be compounded by a further 
invasion of their privacy." 1991 McKinney's Sessions Laws of N.Y., a! 2211-2212 (quoted in 
Deborah S. v. Diorio, 153 Misc.2d 708, 583 N.Y.S.2d 872 (N.Y.City Civ.Ct.1992)); see also 
Coker'. Georgia, 433 U.S. 584, 597, 97 S.G. 2861, 53 L.Ed.2d 982 (1977) ("Short of homicide, 
[rape] is the ultimate violation of self'). 
As to the fourth factor of risk injury, Dr. Kliman has evaluated Jane Does 2-7, and has 
concluded that the childhood sexual abuse at issue has caused features of post-traumatic stress 
disorder (PTSD), including shame, guilt, helplessness, and powerlessness. See Exhibit "A" at ¶¶ 
4-7. Dr. Kliman further states, "it is more probable than not that releasing personal identities 
I0 
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will foster an exacerbation and magnification of symptoms lending to increased risk of 
revictimization and retraumatization." Id. at ¶ 21. Thus, this is not a case analogous to those 
cited by defendant in which the plaintiffs were merely at risk of "personal embarrassment." 
Instead, there is a genuine and immediate risk of psychological harm. 
None of the cases cited by Defendant where courts denied a plaintiff's request for 
anonymity involved victims of childhood sexual assault or evidence of emotional or 
psychological harm that would result from disclosure of the plaintiffs identity. See Doe v. Hartz, 
52 F.Supp.2d 1027 (N.D.lowa 1999); Doe v. Shakur, 164 F.R.D. 359 (E.D.N.Y.1996); Doe v. 
Bell Atlantic Bus. Sys. Servs., 162 F.R.D. 418 (D.Mass.1995); Doe v. Univ. of Rhode Island, 28 
Fed.R.Serv.3d 366, 1993 WL 667341 (D.R.I. Dec. 28, 1993). 
As to the factor of prejudice, the Defendant does not identify how his ability to conduct 
discovery or impeach Jane Does 2-7's credibility has been or will be impaired if these Plaintiffs 
are permitted to proceed under a pseudonym. See a 
213 F.R.D. at 112, Smith, 105 F.Supp.2d 
at 44-45. Other than the need to make redactions and take measures not to disclose these 
Plaintiffs' identities, Defendant will not be hampered or inconvenienced merely by Plaintiffs' 
anonymity in court papers. As set forth above, Defendant already knows their true identities. See 
Aware Woman Center, 253 F.3d at 687 (no prejudice where plaintiff offered to disclose her name 
to defendant); e 213 F.R.D. at 112; Smith, 105 F.Supp.2d at 44-45. 
II. 
DEFENDANT SHOULD NOT BE PERMITTED TO USE 
THE REAL NAMES OF JANE DOES 2-7 IN THIRD-PARTY 
SUBPEONAS EXCEPT FOR THOSE ISSUED TO PERSONS WHOM 
PLAINTIFFS HAVE ALREADY DISCLOSED THEIR SEXUAL ABUSE 
As for the use of Jane Does 2-7's real names in subpoenas issued to non-parties, a party 
may obtain discovery of any non-privileged matter that is relevant to a claim or defense of any 
party. Fed.R.Civ.P. 26(b)(1). However, a district court may limit discovery "for good cause 
11 
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shown" by making "any order which justice requires to protect a party or person from 
annoyance, embarrassment, oppression, or undue burden or expense," including that the 
discovery not be had or that it be had only by a method other than that selected by the party 
seeking discovery. Fed.R.Civ.P. 26(c). Jane Does 2-7 have articulated a specific and substantial 
harm from disclosure of their identities. 
If this Court were to permit Defendant to issue third-party subpoenas containing Jane 
Doe 2-7's real names, the identity of the Defendant, and/or facts pertaining to the nature of the 
case to whomever Defendant wants, it would be akin to requiring these Plaintiffs to use their real 
name in the pleadings. Instead, Jane Does 2-7 propose to voluntarily execute authorizations 
(which would not contain the case names or the identity of the Defendant) to allow Defendant to 
obtain education, employment, and medical records to be used for purposes of this litigation 
only.3 Alternatively, Defendant can obtain the records through a special master, who would 
verify authenticity and completeness of the records. Either of these approaches would not only 
place Jane Does 2-7 at less risk of psychological harm, but would also be more cost-effective and 
efficient. 
CONCLUSION 
Based on the foregoing, Plaintiffs Jane Does 2-7 respectfully request that Defendant's 
Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane 
Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss 
"Sua Sponte" be denied in its entirety, and that Plaintiffs Jane Does 2-7 be permitted to continue 
using their pseudonyms in this litigation. 
Additionally, to avoid public disclosure of the 
Plaintiff's identities in non-party records discovery, Plaintiffs Jane Does 2-7 request that such 
3 Defendant and Plaintiff have previously agreed that education records can be obtained in this 
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discovery be obtained either through Plaintiffs' counsel by means of written authorizations, or by 
the appointment of a special master. 
Dated: June 8, 2009 
Respectfully submitted, 
By: 
s/ Adam D. Horowitz 
Stuart S. Mermelstein (FL Bar No. 
Adam D. Horowitz (FL Bar No. 
MERMELSTEIN & HOROWITZ, P.A. 
Attorneys for Plaintiffs. Jane Doe Nos. 2-7 
18205 Biscayne Blvd., Suite 2218 
Miami, Florida 33160 
Tel: 
Fax: 
manner in lieu of subpoenas. 
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CERTIFICATE OF SERVICE 
I hereby certify that on June 8, 2009, 1 electronically filed the foregoing document with 
the Clerk of the Court using CM/ECF. 1 also certify that the foregoing document is being served 
this day to all parties on the attached Service List in the manner specified, either via transmission 
of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for 
those parties who are not authorized to receive electronically Notices of Electronic Filing. 
/s/ Adam D. Horowitz 
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SERVICE LIST 
DOE vs. JEFFREY EPSTEIN 
United States District Court, Southern District of Florida 
Jack Alan Goldberger, Esq. 
Robert D. Critton, Esq. 
Bradley James Edwards 
Isidro Manuel Garcia 
Jack Patrick Hill 
Katherine Warthen Ezell 
Michael James Pike 
Paul G. Cassell 
Richard Horace Willits 
Robert C. Josefsberg 
/s/ Adam D. Horowitz 
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professional publications include books and peer-reviewed medical journal articles on mass 
disasters, most recently concerning the Attack on America. 
He was extensively interviewed in 1997 by CBS Dallas TV regarding psychiatric testimony 
concerning eleven altar boys, testimony which had resulted in a record-making jury verdict 
against the Archdiocese of Dallas. In April, 1998, Dr. Kliman was interviewed by Channel Four 
anchorwoman, Linda Yee, concerning his Salvation Amy project providing the Cornerstone 
form of psychoanalytic psychotherapy for homeless preschoolers and toddlers,. The Cornerstone 
project itself was viewed on the Channel II Five O'Clock News. KGO TV interviewed Dr. 
Kliman concerning a forensic testimony, with a focus on a Stanford football player who had 
allegedly become a child molester. During the Lewinsky-Clinton matter, Kliman was 
interviewed by Channel 12/20 concerning psychoanalytic views of leaders having exceptional 
sexual access to partners and the risk of a position of power overcoming the judgments of such 
leaders. 
During 2001 following the World Trade Building terrorism, Dr. Kliman was 
interviewed by Channel II News and appeared on five occasions thereafter through 2003 
concerning the Afghanistan and Iraq wars. In May 2003, he was discussant with U.N. Secretary 
General Olaru Otonu, featured on Dhubai Business TV concerning the plight of children in war. 
In 2004, together with the International Psychoanalytic Association, Dr. Kliman helped organize, 
establish and supervise a therapeutic preschool project in Buenos Aires. 
"Cornerstone 
Argentina" is now in its second year of treating severely disturbed and impoverished 
preschoolers, with his continuing collaboration. 
Following the hurricane disasters of 2005 he collaborated with Mercy Corps and the Children's 
Psychological Health Center to produce a mental health resource. The result, "My Katrina and 
Rita Story", a guided activity resource of families who had to deal with the hurricanes. Mercy 
Corps is distributing copies to 20,000 families. 
In 2005, RE DISTURBED PRESCHOOLERS Dr. Kliman helped organize, establish and 
supervise a therapeutic project in Piedmont California, at the nonprofit Ann Martin Center. 
In 2007, RE HOMELESS CHILDREN: Dr. Kliman helped establish a Reflective Network 
Therapy service for homeless preschoolers in Seattle. He provided four days of training in that 
method for the Family Service Center of King County (located in Seattle), and created an 
organizational link between The Family Services Center and The Children's Psychological 
Health Center, Inc. of San Francisco in order to continue serving homeless children in Seattle. 
In 2008, Dr. Kliman activated the Reflective Network Therapy services for preschoolers in 
Seattle. He supervises there in person and by phone and video. 
In 2008, RE DISASTER SERVICES: Following the Sichuan Earthquake Disaster of May 12, 
2008, Dr. Kliman established a link between Children's Psychological Health Center, Inc., 
Mercy Corps, and The China America Psychoanalytic Alliance. He created mental health 
resources (see Publications) which were licensed for mass distribution in China by Mercy Corps. 
In 2008, Dr. Kliman helped found a new non-profit organization called Teach with Africa and is 
a member of its Board of Directors. 
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